Tài liệu Financial Services Authority Business Continuity Management Practice Guide pptx

Financial Services Authority
Business Continuity
Management
Practice Guide
November 2006
Business Continuity Management Practice Guide
Introduction 1
How to use the Guide 2
How the FSA will use the Guide 4
Table of contents 5
A. Corporate Continuity 6
B. Corporate Crisis Management 13
C. Corporate Systems 18
D. Corporate Facilities 26
E. Corporate People 29
Contents
© The Financial Services Authority 2006

Business Continuity
Management Practice Guide
1
Introduction
Background
During 2005, the Tripartite Authorities (FSA, Bank of England and HM
Treasury) carried out the Resilience Benchmarking Project
1
. The project was
designed to assess the resilience and recovery capability of the UK financial
services sector in the event of major operational disruption such as a terrorist
attack or natural disaster. We define major operational disruption as an incident

having widespeard impact on more than one organisation, that has a severe
impact on firms, and that requires the implementation of special arrangements
for continued operations of critical business functions.
The project provided us with a valuable insight into the overall business
continuity preparedness of more than 60 firms that took part in the
Benchmarking exercise, answering more than 1,000 questions on their
business continuity arrangements. With their agreement we have produced
this Business Continuity Management Practice Guide in the spirit of sharing
lessons learned from the project so that firms that did not participate can also
benefit from it. The Guide is based on real examples of standard and leading
practices we observed in the firms that participated. It reflects the collective
business continuity planning and crisis management expertise of the UK’s
most significant firms and financial infrastructure providers.
Purpose
The Business Continuity Management Practice Guide is not general guidance
from the Tripartite Authorities, nor is it guidance on FSA rules. Rather, it aims
to help regulated firms in their business continuity planning by identifying and
1 For more information see
www.fsc.gov.uk/upload/public/Files/9/Web%20-%20Res%20Bench%20Report%2020051214.pdf.
sharing examples of business continuity practice observed in firms that
participated in the benchmarking exercise. We hope that these observations
may be useful for firms when reviewing their own business continuity and
crisis management arrangements. Firms should not view the Guide as a
definitive checklist of steps to take, but rather as a flexible tool to stimulate
their thinking and provide a framework for the development of their own
plans. Above all else, firms should continue to be mindful of their individual
circumstances and risk profiles when considering what may – or may not – be
appropriate for their business.
Examples of observed practice are grouped by topic and organised by theme
into modules:

Corporate Continuity
Corporate Crisis Management
Corporate Systems
Corporate Facilities
Corporate People
The modules capture the various components of business continuity planning
and testing and provide a framework for building resilience and recovery
capability. By defining clearly elements of processes like risk identification or
crisis team activation, the Guide may help firms improve their business
continuity planning.
How to use the Guide
Observed standard practice – observed leading practice
Two levels of observed practice are identified within the Guide:
• Observed standard practice generally reflects the practices
adopted by most of the 60 benchmarking participants.
• Observed leading practice generally reflects the practices
adopted by the highest scoring 20% of the 60 benchmarking
participants, and tends to denote more robust or sophisticated
practices.
In a handful of cases we exercised discretion and included examples of observed
standard practice which did not meet the above criteria, but which we considered
helpful or important to include nonetheless. These instances represent fewer than
7% of all of the examples of sound practice contained in this Guide.
2
Risk based approach
This Guide is not intended to be a comprehensive list of all the business
continuity practices relevant to a financial firm. Therefore, the FSA does not
expect firms to take a tick-box approach to using the Guide. Instead, firms are
encouraged to take a pragmatic and sensible view of which aspects of the
Guide are most useful and relevant for them. For example, firms may wish to:

• ‘Mix and match’ across observed standard and leading
practices as they see fit, adapting their plans to reflect their
individual risk profile and the complexity of their activities.
• Exercise common sense when deciding which aspects of the
Guide are most relevant to them. For instance, various
examples of observed leading practice may be more relevant to
very large firms or firms with very large exposure to specific
markets, whereas smaller or less complex firms may not
necessarily need to have such sophisticated plans.
• Adopt more sophisticated arrangements than the examples
provided as observed leading practice.
Differentiating between observed standard practice and observed
leading practice
• Observed standard practice sets out the general practice
observed in each area. The corresponding observed leading
practice either supplements or completely replaces the observed
standard practice. For an example of where observed leading
practice replaces observed standard practice, refer to Module A
Section 3.3.1.
• Where observed standard and leading practice appear to be
very similar, the key differences are shown in italics. For an
example of this, refer to Module A Section 3.3.3.
• In some cases we have set out observed standard practice only.
This is because we have either not observed a higher standard,
or because only a very small number of benchmarking
participants met a higher standard. For an example of this,
refer to Module A Section 3.2.2.
• In other cases, we have set out observed leading practice only.
This is because there were insufficient responses to justify its
inclusion as standard practice; however, we considered it

3
sufficiently important to merit inclusion as a positive example
of good business continuity practice. Consequently, these
examples have been included as observed leading practice, with
no corresponding standard example. For an example of this,
please refer to Module A Section 2.2.1.
How the FSA will use the Guide
The Guide does not form part of the FSA’s formal rules and guidance. So, just
as we would expect firms to exercise their common sense and judgement
regarding which aspects of the Guide are likely to be most relevant to them,
supervisors will be similarly pragmatic. We anticipate that the Guide will
provide a useful basis around which firms and their supervisors can structure
their discussions on business continuity planning, while bearing in mind that
individual firms’ arrangements should be proportionate to the nature and
scale of their business and appropriate to their individual risk profile.
4
A. Corporate Continuity
A.1 Business continuity
planning
A.1.1 Risk assessment
A.1.2 BCP strategy
A.2 BCP design
A.2.1 Critical suppliers
A.2.2 Responding to
requests for BCP
information from third
party organisations
A.2.3 Outsourcing contract
providers
A.2.4 Critical paper assets

A.3 Resources
A.3.1 BCP team
A.3.2 Staff and BCP
A.3.3 Third parties and BCP
A.4 Plan review
A.4.1 BCP audit
A.4.2 BCP changes
A.4.3 Testing
A.4.4 Documentation
A.4.5 Recovery service
providers
A.5 Recovery times for
critical functions
A.5.1 Trade clearing
A.5.2 Settlement
A.5.3 Wholesale payments
B. Corporate Crisis
Management
B.1 Culture
B.1.1 Strategy
B.1.2 Audit and review
B.1.3 Accessibility
B.1.4 Senior management
B.2 Team
B.2.1 Crisis
management team
B.2.2 Team activation
B.2.3 Team attributes
B.2.4 Team support
B.2.5 Facilities

B.3 Communications
B.3.1 Communication
strategy
B.3.2 Internal and external
communications
C. Corporate Systems
C.1 Information
Technology (IT)
C.1.1 Identification of risks
C.1.2 Identification of
critical IT
C.1.3 Recovery
C.1.4 Providers
C.1.5 Network resilience
C.1.6 IT resilience
C.1.7 Data
C.1.8 Security
C.1.9 Site
C.1.10 Alternate site
C.1.11 Review, audit and
changes
C.1.12 Testing
C.2 Telephony
C.2.1 Recovery
C.2.2 Site
C.2.3 Testing
D. Corporate Facilities
D.1 Planning
D.1.1 Planning
D.1.2 Energy

D.1.3 Water
D.1.4 Security
D.1.5 Evacuation
D.1.6 Emergency services
D.1.7 Testing
E. Corporate People
E.1 Staff
E.1.1 BCP awareness
E.1.2 Training
E.1.3 Staff planning
E.1.4 Key staff
E.1.5 Checks
E.1.6 Tests
E.2 Crisis management
E.2.1 Contacting staff
E.2.2 Staff welfare
Table of contents
5Business Continuity Management Practice Guide
6 Business Continuity Management Practice Guide
Business Continuity Management Practice Guide
A. Corporate Continuity
A.1 Business
Continuity
Planning (BCP)
Observed standard practice Observed leading practice
A.1.1
Risk assessment
A.1.1.1
A.1.1.2
• Detailed risk assessments are carried out annually or

when there is a change in normal operations.
• All impact assessments are current and have been
reviewed and updated in the past year.
A.1.2
BCP strategy
A.1.2.1
A.1.2.2
A.1.2.3
A.1.2.4
A.1.2.5
A.1.2.6
A.1.2.7
• A BCP reflecting identified risks exists for all
departments.
• Plans consider time of the day, year and other
business cycles.
• Plans have identified the impact to business in a
disaster for all functions and they specify timescales
and priorities for recovering these functions.
• Plans reflect the impact a major operational
disruption would have on the business.
• Planning considers total destructive loss of the site
and any operational disruption including some loss
of staff.
• Plans are written and owned by decentralised plan
owners. Alternatively, centralised plans are written by
the Business Continuity function with departmental
plans maintained by decentralised plan owners.
• Web-based plans are accessible anywhere but all key
staff also carry quick reference cards. Alternatively, a

mix of paper, reference cards and/or electronic
and/or web-based is accessible at all times.
As for observed standard practice but:
• Planning considers wide area destruction and any
operational disruption involving significant loss
of staff.
7Business Continuity Management Practice Guide
8 Business Continuity Management Practice Guide
A.2 BCP design
Observed standard practice
Observed leading practice
A.2.1
Critical suppliers
A.2.1.1 • Firm has liaised with critical suppliers regarding their
arrangements.
• Critical suppliers are involved in tests on an at least
annual basis.
A.2.2
Responding to
requests for BCP
information
from third party
organisations
A.2.2.1 • Firm supplies evidence of its capability and testing.
A.2.3
Outsourcing
contract
providers
A.2.3.1 • Requirements on providers are included in formal
terms in the contract.

• Requirements on providers, including participation
or auditing of tests, are included in formal terms in
the contract.
A.2.4
Critical paper
assets
A.2.4.1
A.2.4.2
A.2.4.3
A.2.4.4
A.2.4.5
• Critical paper assets are managed through systematic
classification according to criticality.
• Critical paper assets are filed on a managed basis and
put in fireproof cabinets to avoid destruction.
• Replicated paper records can be accessed within one
working day of an incident.
• Scanned data for critical functions can be recovered
and used at recovery site immediately.
As for observed standard practice but:
• Critical paper assets are managed with a classification
scheme that includes impact or criticality.
• Critical paper documentation is replicated on a
managed basis within one week of creation or change.
• Scanned data can be recovered and used at recovery
site immediately for all data.
9Business Continuity Management Practice Guide
A.3 Resources
Observed standard practice
Observed leading practice

A.3.1
BCP team
A.3.1.1
A.3.1.2
• Most team members are competent in all disciplines
or areas defined by the Business Continuity Institute.
• Team members understand critical functions and are
able to represent most of their continuity interests.
As for observed standard practice but:
• All team members are competent in all disciplines or
areas defined by the Business Continuity Institute.
• Team members fully understand critical functions
and are able to converse fluently with specialists in
each critical area.
A.3.2
Staff and BCP
A.3.2.1
A.3.2.2
A.3.2.3
A.3.2.4
• If there is a Trade Union presence in the
organisation, it was consulted on BCP.
As for observed standard practice but:
• More than 20% of UK staff have business continuity
as part of their objectives.
• If the plan’s activation is expected to result in
additional workload, the need and deployment of
temporary or contract staff has been planned in detail.
• Plans make provision for transportation of staff
under certain disruption conditions.

A.3.3
Third parties
and BCP
A.3.3.1
A.3.3.2
A.3.3.3
• Plans reflect consultation of local emergency services’
response plans and include reference materials.
• Plans take into account provisions of the Civil
Contingencies Act.
• Insurance policy details are included in the plans.
• Local authority emergency plans and emergency
services’ response plans are reflected in the plan.
• Insurance details and procedures agreed with insurers
are included in the plans.
10 Business Continuity Management Practice Guide
A.4 Plan review
Observed standard practice
Observed leading practice
A.4.1
BCP audit A.4.1.1
A.4.1.2
A.4.1.3
• Plans are subject to internal and external audit.
• Business continuity planning appears on Board’s
agenda at least twice each year.
• Business continuity planning appears on Risk and
Audit committees’ agendas at least every quarter.
As for observed standard practice but:
• There is a clear, documented and approved audit

cycle covering all locations and functions.
• Business continuity planning appears on Board’s
agenda at least every quarter.
A.4.2
BCP changes
A.4.2.1
A.4.2.2
• Business continuity is always considered as part of a
formal change control process ensuring all relevant
components are reviewed before change takes place.
• Business continuity documents are updated when a
test is completed or when a major change occurs.
As for observed standard practice but:
• Detailed risk and impact assessments and plan
updates are carried out to build business continuity
into a change in management processes.
A.4.3 Testing
A.4.3.1
A.4.3.2
A.4.3.3
A.4.3.4
A.4.3.5
A.4.3.6
• At least 75% of all business functions have been
tested in the last two years.
• Tests involve integrated simulation, involving IT,
facility and critical staff recovery using alternate
facilities.
• Out-of-hours telephone contact tests are conducted
at least once per year.

• Representatives from all areas and at all levels,
including senior management, are involved in tests.
• Neighbouring businesses and emergency services are
consulted about testing.
• The testing schedule is current and published within
the organisation.
As for observed standard practice but:
• Out-of-hours telephone contact tests are conducted
at least once every six months.
• All staff are involved in tests.
• Neighbouring businesses and emergency services are
involved in some tests.
11Business Continuity Management Practice Guide
A.4.4
Documentation
A.4.4.1
A.4.4.2
• Pre-test documentation is available before testing.
• After the test, reports are all completed with clear
actions and owners.
A.4.5
Recovery service
providers
A.4.5.1 • If recovery service providers are used, their capacity
to cope with multiple concurrent usage
has been tested.
12 Business Continuity Management Practice Guide
A.5 Recovery
times for critical
functions

Observed standard practice
Observed leading practice
A.5.1
Wholesale
payments
The firm avoids entering into new business unless it is
confident it can meet its obligations as they fall due.
From the point of invocation all material pending
transactions falling due that day are settled by close
of business.
On the next working day the following transactions are
settled by close of business:
• Any outstanding transactions falling due the
previous day that have been rolled over;
• All transactions falling due that day.
A.5.2
Trade clearing
The firm avoids entering into new business unless it is
confident it can meet its obligations as they fall due.
From the point of invocation all material pending
transactions falling due that day are settled by close
of business.
On the next working day the following transactions are
settled by close of business:
• Any outstanding transactions falling due the
previous day that have been rolled over;
• All transactions falling due that day.
A.5.3
Settlement
The firm avoids entering into new business unless it is

confident it can meet its obligations as they fall due.
From the point of invocation all material pending
transactions falling due that day are settled by close
of business.
On the next working day the following transactions are
settled by close of business:
• Any outstanding transactions falling due the
previous day that have been rolled over;
• All transactions falling due that day.
13Business Continuity Management Practice Guide
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B. Corporate Crisis Management
14 Business Continuity Management Practice Guide
B.1 Culture
Observed standard practice
Observed leading practice
B.1.1
Strategy B.1.1.1
B.1.1.2
B.1.1.3
• A detailed current crisis management plan is in place.
• The crisis management plan contains instructions on
how to respond to the issue of casualties and fatalities.
• The crisis management strategy allows operations to
continue indefinitely, allowing for some reduction of
throughput.
As for observed standard practice but:
• Instructions on responding on the issue of casualties
and fatalities have been verified during tests.
• The crisis management strategy allows operations to

continue indefinitely with no reduction of throughput.
B.1.2
Audit and review
B.1.2.1 • Adjustments to the plan are made when threats
change significantly.
• There is a regular formal review and update process,
irrespective of changes of threats.
B.1.3
Accessibility
B.1.3.1 • The crisis management plan is accessible in a mix of
media including:
• paper plans;
• electronic plans;
• web-based plans; and
• reference cards which are accessible at all times.
B.1.4
Senior
management
B.1.4.1
B.1.4.2
B.1.4.3
B.1.4.4
• The executive management team knows who is in the
crisis management team and has approved their
selection.
• The executive management team understands the
crisis management team’s remit. They have agreed to
them running the crisis, approved their empowerment
and signed off the plan.
• The agreed roles of the executive or senior

management during an incident are contained in the
crisis management plan and they have been signed
off by the individuals concerned.
• If the senior management team is located overseas,
UK offices are aware of its plan to manage a crisis.
15Business Continuity Management Practice Guide
B.2 Team
Observed standard practice
Observed leading practice
B.2.1
Crisis
management
team
B.2.1.1
B.2.1.2
B.2.1.3
B.2.1.4
B.2.1.5
B.2.1.6
B.2.1.7
• The crisis management team is responsible for
managing all critical internal and external issues to
resolution.
• The crisis management team has a clear and formal
structure.
• Responsibilities and alternates exist for all roles.
• At least 70% of crisis management team members
and deputies have been involved in tests or incidents
in the past 12 months.
• The core crisis management team may be

supplemented by pre-selected and trained specialists
according to incident type, scale and severity.
• The crisis management team has demonstrated
capability in tests.
• The crisis management team’s membership is stable,
and any necessary changes kept to a minimum.
B.2.2
Team activation
B.2.2.1
B.2.2.2
B.2.2.3
• The crisis management team is invoked following
certain agreed disruptive circumstances.
• The crisis management team can be activated
according to defined escalation mechanism.
• Following activation, the team is formed by one or
more of these options according to circumstances:
• conference call with further assembly at an
agreed location (primary or secondary);
• pre-defined standard meeting places and times; and
• assembly at a pre-defined location or secondary
location.
16 Business Continuity Management Practice Guide
B.2.3
Team attributes
B.2.3.1
B.2.3.2
• Once activated, the crisis management team has full
authority for all decisions.
• The crisis management team has clear spending

powers during a crisis (their use and extent have
been pre-approved).
B.2.4
Team support
B.2.4.1 • The plan provides for named individuals to be
seconded to the crisis management team to provide
operational support on an as-needed basis.
• The crisis management team is provided with
planned and pre-identified staff during a crisis to
provide operational support (e.g. assistants,
analysts and auditors).
B.2.5
Facilities
B.2.5.1
B.2.5.2
B.2.5.3
• If the site is inaccessible, the crisis management
team is accommodated in a pre-prepared primary or
secondary location at least on kilometre from the
affected site.
• If the site can still be used, the crisis management
team is accommodated in a pre-prepared crisis
management room or command centre.
• The primary command centre location to support the
crisis management team is fully equipped to operate
as a dedicated crisis command centre (e.g. stationery,
telephones, printers, PCs, TVs, desks, conferencing).
17Business Continuity Management Practice Guide
B.3
Communications

Observed standard practice
Observed leading practice
B.3.1
Communications
strategy
B.3.1.1
B.3.1.2
B.3.1.3
• The crisis management communication plan covers
internal and external communications with staff, peer
organisations, the media and other stakeholders.
• There is a clearly defined process for dealing with the
media and public relations during a crisis and it has
been verified during tests.
• The crisis management team including key
communications staff, and general management are
familiar with the crisis management communications
plan.
As for observed standard practice but:
• All staff with specific requirements placed on them
by the plan are familiar with the crisis management
communications plan.
B.3.2
Internal and
external
communications
B.3.2.1
B.3.2.2
B.3.2.3
• The external communications or public relations plan

has been tested responding to crises affecting the
organisation.
• Telephone or mobile phone call cascade or automated
calling systems are used for communicating
instructions and status information to staff at the
start of a crisis.
• During a crisis staff can contact the business through:
• a telephone number that they know they can call;
and/or
• a widely publicised 24-hour manned emergency
contact number.
• Dedicated web pages or recorded message or call
centre contact are used for communicating
instructions and status information to staff at the
start of a crisis.
18 Business Continuity Management Practice Guide
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C. Corporate Systems
19Business Continuity Management Practice Guide
C.1 IT
Observed standard practice
Observed leading practice
C.1.1
Identification
of risks
C.1.1.1
• Plans identify:
• points of consistency of data for recovery;
• consequences of allowing non-affected systems to
continue when others are non-operational; and

• any unique critical system (and its recovery is
reflected in the plans).
C.1.2
Identification
of critical IT
C.1.2.1
C.1.2.2
C.1.2.3
• A fully detailed impact analysis on loss of IT has
been performed to identify which of the
organisation’s IT systems and infrastructure are the
most business critical.
• There is an ongoing continuous process or cycle to
analyse and document the criticality of the
organisation’s IT systems.
• A systematic dependency analysis has been performed
covering most critical areas of IT to evaluate the
impact of an individual IT system failure.
As for observed standard practice but:
•A fully detailed and authorised IT dependency
analysis has been performed to evaluate the impact
of an individual IT system failure.
20 Business Continuity Management Practice Guide
C.1.3
Recovery
C.1.3.1
C.1.3.2
C.1.3.3
C.1.3.4
C.1.3.5

C.1.3.6
C.1.3.7
C.1.3.8
C.1.3.9
C.1.3.10
IT restoration plans address the following:
• restoration of all IT systems according to business
conditions;
• the time needed to recover IT at all critical sites;
• all aspects of critical systems recovery is carried out
by the firm’s staff;
• restoration of connectivity to critical networks;
• restoration (including tests) of critical computer
systems and associated hardware;
• where mirror systems are used, backup devices and
software are in place to manage backups from a
single replicated system when the primary has failed;
• permanent connections to recovery sites to recover wide
area network communications for systems and users;
• eventual recovery of every system; and
• the return of IT operations to their original site.
As for observed standard practice but:
• There are detailed procedures for prioritising IT
recovery according to business conditions.
• There are plans to restore the development
environment.
C.1.4
Providers
C.1.4.1
C.1.4.2

C.1.4.3
• All critical sites use more than one telecoms provider
for voice and data. The following interactions take
place with providers:
• planned formal meetings take place to plan
resilience of the communications network;
• planned verification takes place to check the
resilience of telecoms providers’ network architecture
and of the connectivity and routing within it; and
• verification of IT third party suppliers’ disaster
recovery capability.
• Procedures as to how the disaster recovery providers
will manage a multiple invocation of their sites is
known, documented and agreed;
• Assurance has been given by providers that
separacy/diversity services are in place in the wide
area network.
As for observed standard practice but:
• Continuous interaction with planned formal
meetings takes place to plan resilience into
communications network.
• Detailed planned and formal reviews take place
to verify the resilience of telecoms providers’
network architecture and of the connectivity and
routing within it.
21Business Continuity Management Practice Guide
C.1.5
Network
resilience
C.1.5.1

C.1.5.2
C.1.5.3
C.1.5.4
C.1.5.5
C.1.5.6
• There is an up-to-date and detailed network diagram
in IT plans.
• All aspects of network continuity are proactively and
formally managed.
• Networks are designed to be fully redundant with no
single points of failure.
• Network availability figures are monitored for trends
as well as threshold exception basis and the
information is used to identify points of weakness.
• The full control and visibility of wide area network
assets needed to provide end-to-end separation can be
demonstrated (e.g. through documentation) internally.
• Wide area network communications can be restored at
work area recovery sites in less than one hour.
As for observed standard practice but:
• The full control and visibility of your wide area
network assets needed to provide end-to-end
separation can be demonstrated (e.g. through
documentation) internally and externally.
C.1.6
IT resilience
C.1.6.1
C.1.6.2
C.1.6.3
C.1.6.4

C.1.6.5
• No critical system depends on an individual person
for restoration in a disaster.
• Critical IT systems are spread across diverse locations.
• If buildings and content and non-replicated data
were destroyed, this would create backlogs smaller
than one week.
• In an incident affecting the most critical IT site, all
of the affected critical IT systems could be recovered
within four hours from invocation.
• If replicated critical systems are used and both sites
are lost, recovery can still take place.
As for observed standard practice but:
• If buildings and content and non-replicated data
were destroyed, this would create no noticeable
backlogs or impact on operations.
• In an incident affecting the most critical IT site, all
of the affected critical IT systems could be
recovered within two hours from invocation.
• If replicated critical systems are used and both sites
are lost, recovery can still take place within agreed
business timeframes.
C.1.7
Data
C.1.7.1
C.1.7.2
• All critical data are copied or they are replicated at
another site.
• It takes less than one hour to retrieve off-site copies
of critical recovery data (where applicable).